Institutional document · Version 1.0 · September 2026

Code of Ethics and Conduct

Purpose · Mission · Vision · Values · Principles and Conduct Guidelines

1

Introduction

This Code of Ethics and Conduct establishes the principles, values and behavioral standards expected of everyone acting on behalf of GGR Andrade Logística e Transportes Ltda., including owners, directors, employees, drivers, service providers, representatives, partners and any other persons who may represent the company.

The document supports a culture of safety, respect, integrity, quality and excellence, especially in executive transportation and passenger logistics for corporate clients and the Oil & Gas, Offshore, Maritime, port and other environments where trust and operational discipline are essential.

“We do more than transport passengers. We deliver trust.”

2 · 3 · 4

Purpose, mission and vision

Purpose

To connect people with their destinations safely, reliably, respectfully and excellently, making every journey a calm and professional experience.

Mission

To provide executive transportation and passenger logistics solutions with safety, punctuality, comfort and operational excellence, meeting the needs of clients in the corporate, Oil & Gas, Offshore, Maritime and other sectors that require reliable mobility.

Vision

To be recognized as a leading executive transportation and passenger logistics company, distinguished by safety, reliability, quality, discretion, punctuality and service excellence.

5

Our Values

Safety

People’s lives, physical integrity and well-being always come first.

Ethics

We do what is right, transparent and responsible, even when no one is watching.

Trust

We keep our promises and treat every commitment as a responsibility.

Punctuality

We respect our clients’ time and understand how delays can affect an entire operation.

Respect

We treat clients, colleagues, partners, suppliers and communities with courtesy, dignity and professionalism.

Excellence

We pursue continuous improvement and quality in every service, journey and interaction.

Responsibility

We take care of the people, vehicles, equipment, information, resources and property entrusted to us.

Human-Centered Service

We recognize that every passenger is an individual with their own story, needs and expectations.

6

Fundamental Principles

  • Safety takes precedence over commercial, operational or scheduling pressure.
  • Integrity guides decisions, relationships and business dealings.
  • Everyone deserves respectful, professional treatment free from harassment or discrimination.
  • Client, passenger, contract and operational information must be handled discreetly and responsibly.
  • Company resources and property must be used properly, economically and responsibly.
  • Irregularities, risks and incidents must be reported promptly and responsibly.
  • The company seeks business relationships based on transparency, fair competition and compliance with applicable law.

Sections 7–21

Conduct Guidelines

Everyone acting on behalf of GGR must:

  • maintain a professional, courteous and discreet attitude in all circumstances;
  • observe schedules, procedures and commitments;
  • protect the company’s image and reputation;
  • act honestly and in good faith;
  • immediately report any circumstances that could compromise safety or service quality;
  • never conceal relevant information concerning accidents, damage, delays, incidents or deviations;
  • comply with internal policies, contracts, legislation and the requirements of the locations served;
  • seek guidance from management whenever there is uncertainty about the appropriate course of conduct.

Safe driving is a non-negotiable obligation. Drivers and other professionals involved in operations must practice defensive driving, comply with speed limits, traffic signs and traffic laws, and perform all required vehicle inspections and procedures.

  • Driving under the influence of alcohol, drugs or any substance that impairs driving ability is strictly prohibited.
  • Mobile phone use while driving must fully comply with applicable laws.
  • All occupants must wear seat belts.
  • Mechanical failures, tire problems, brake defects, lighting issues or any other unsafe condition must be reported immediately.
  • No scheduling target or deadline justifies reckless driving or exposing people to risk.
  • Welcome passengers courteously, respectfully and discreetly.
  • Confirm necessary operational information without disclosing unnecessary personal data.
  • Keep vehicles clean, organized, sanitized and suitable for the agreed service standard.
  • Avoid conversations, questions or personal comments that could make passengers uncomfortable.
  • Respect reasonable customer preferences regarding silence, temperature and comfort.
  • Never argue with, confront or raise your voice at passengers or business partners.
  • In the event of a complaint, listen carefully, document the matter and refer it to the responsible person.

Information concerning passengers, clients, routes, schedules, contracts, operations, prices and other data obtained through work is confidential and must be handled in accordance with applicable legislation, including personal data protection requirements.

  • Do not disclose passenger itineraries, destinations or personal information without authorization or a legitimate operational need.
  • Do not photograph or film passengers, facilities or operations without authorization.
  • Do not publish information on social media that could identify clients, routes, contracts or confidential operations.
  • Use information solely for authorized professional purposes.

Operations conducted in controlled environments require discipline and strict compliance with the safety and access procedures established by each client, terminal, port, airport, vessel or facility.

  • Comply with accreditation, access, identification and security procedures.
  • Respect restricted areas and never enter unauthorized locations.
  • Use personal protective equipment (PPE) and comply with other safety requirements whenever required.
  • Follow instructions issued by the site’s security and emergency response teams.
  • Do not transport materials, people or cargo in violation of the rules established by the contracting party or facility.
  • Immediately report any hazardous situation, incident or emergency.

GGR does not tolerate corruption, fraud, bribery, improper favoritism or any practice intended to obtain an unlawful advantage. Everyone must act transparently and comply with applicable laws.

  • Do not offer, promise, authorize, request or accept improper advantages.
  • Do not make payments or offer favors intended to improperly influence decisions.
  • Avoid situations in which personal interests may interfere with professional decisions.
  • Report potential conflicts of interest to management.
  • Maintain truthful and appropriate business records and information.

Gifts and hospitality are acceptable only when legitimate, reasonable, transparent, consistent with the professional relationship and not intended to influence a commercial or operational decision. Whenever in doubt, the professional must consult management before offering or accepting any benefit.

GGR does not tolerate workplace harassment, sexual harassment, intimidation, humiliation, threats or any form of abusive treatment in the professional environment.

  • Respect individual and professional differences.
  • Do not use offensive, discriminatory or humiliating language.
  • Do not engage in or encourage behavior that creates a hostile environment.
  • Report serious or recurring situations through the company’s available reporting channels.

Operational safety depends on the full physical and mental fitness of professionals. Working under the influence of alcohol, illegal drugs or any substance that compromises driving ability, judgment or the performance of duties is incompatible with operational activities.

  • Use vehicles and equipment exclusively for authorized purposes.
  • Protect and maintain company assets, ensuring their proper condition, cleanliness and safety.
  • Record and report damage, accidents, losses or irregularities.
  • Do not allow unauthorized third parties to use company vehicles.
  • Avoid waste and use resources responsibly.

Personal participation on social media must respect client privacy and protect GGR’s reputation. Internal information, passenger images, documents, contracts, restricted facilities or operational situations must not be disclosed without authorization.

  • Seek to reduce waste and minimize the environmental impacts associated with our operations.
  • Ensure the proper disposal of waste.
  • Avoid practices that may cause environmental harm.
  • Support responsible relationships with communities, clients and partners.
  • Promote the conscious use of fuel, water, energy and materials.
  • Our fleet is progressively transitioning from internal combustion engine vehicles to hybrid and electric vehicles, aiming to reduce environmental harm and promote the use of sustainable energy sources.

In any incident, the priority is to preserve lives and control risks. Professionals must follow the applicable emergency procedures, contact the appropriate response resources and immediately notify management.

  1. Protect your own safety and the safety of others whenever possible.
  2. Contact emergency services, authorities or operational support as appropriate to the situation.
  3. Provide assistance within the limits of your abilities and training, without taking unnecessary risks.
  4. Notify the company of the incident as soon as possible.
  5. Preserve information and evidence required for investigation.

Anyone who identifies potentially illegal, unethical or unsafe conduct must report the matter to management or through a channel that may be officially made available by the company. Reports must be handled seriously, confidentially and respectfully.

GGR must not tolerate retaliation against anyone who, in good faith, reports a concern or irregularity.

Compliance with this Code is everyone’s responsibility. Ignorance of a rule does not justify conduct that places people, clients, property or the company’s reputation at risk.

This Code must serve as a reference for everyday decisions. When a situation is not expressly addressed, common sense, safety, ethics, applicable laws and guidance from management must prevail.

23

Company Information

Legal name: GGR Andrade Logística e Transportes Ltda.

CNPJ (Brazilian company registration): 68.912.841/0001-09

Email: contato@ggrandrade.com.br

Phone: +55 22 99857-3070

Address: Avenida América do Norte, No. 92, Casa 19, Alphaville, Rio das Ostras, RJ, Brazil — ZIP code 28898-332


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